Paycheck Protection Program
Last Reviewed: July 2020
The Paycheck Protection Program (PPP) is a part of the CARES Act and is a loan designed to provide a direct incentive for small businesses (generally less than 500 employees, including sole proprietorships, independent contractors and self-employed persons) to keep their workers on the payroll. The SBA will forgive loans if all employees are kept on the payroll for 8 weeks and the money is used for payroll, rent, mortgage interest or utilities. All federally insured credit unions are eligible to be a lender for this program, which has minimal underwriting requirements. Credit unions that are already SBA-certified lenders will immediately have the authority to process PPP loans. Parker and Audrey Koelzer. Credit unions interested in providing these loans to their members who are not already SBA lenders will need to submit applications and apply to the SBA. Lenders can begin processing applications on April 3, 2020 and the program will be available through August 8, 2020 or until funds are no longer available.
Paycheck Protection Program: FAQs
- ECOA Notice of Action Taken for PPP Loans FAQs
- FinCEN Paycheck Protection Program FAQs (2/1/2021)
- How to Calculate Maximum Loan Amounts (PPP) – FAQs
- Participation of Faith-Based Organizations in PPP and EIDL - FAQs
- Paycheck Protection Program Questions
- PPP Loan Forgiveness FAQs (8/13/2020)
- US Treasury Paycheck Protection Program Loans – FAQs
Paycheck Protection Program: Laws & Regulations
- Extension of PPP Loan – Revision to Final Rule (07/04/2020)
- PPP: Interim Final Rule
- PPP: Interim Final Rule (4/14/2020)
- PPP: Interim Final Rule (4/24/2020)
- PPP: Interim Final Rule (4/27/2020)
- PPP: Interim Final Rule - Review Procedures and Related Borrower and Lender Responsibilities (5/22/2020)
- PPP: Interim Final Rule – Requirements Loan Forgiveness (5/22/2020)
- PPP: Revisions to First Interim Final Rule (6/10/2020)
- PPP: Additional Revisions to First Interim Final Rule (6/12/2020)
- PPP: Interim Final Rule – Additional Revisions to Loan Forgiveness and Loan Review Procedures (10/9/2020)
- PPP: Interim Final Rule - Treatment of Owners and Forgiveness of Certain Payroll Costs (8/24/2020)
- Parker and Audrey Koelzer
2021 Changes to PPP:
- PPP: Interim Final Rule – Business Loan Temporary Changes; PPP as Amended by American Rescue Plan (3/11/2021)
- PPP: Interim Final Rule – Business Loan Program Temporary Changes; PPP as Amended by Economic Aid Act (1/12/2021)
- PPP: Interim Final Rule – Business Loan Program Temporary Changes; PPP Second Draw Loans (1/12/2021)
- PPP: Interim Final Rule – Business Loan Program Temporary Changes; PPP – Revisions to Loan Amount Calculation and Eligibility (3/8/2021)
Paycheck Protection Program: Additional Resources
- FinCEN Releases COVID-19 Relief on Certain Beneficial Ownership and CTR Requirements for PPP Applicants
- Lender Information Fact Sheet
- SBA FAQs (Issued 3/3/2021)
- SBA First Draw Form 2483 (Paycheck Protection Program Application Form) (Rev. 3/3/2021)
- SBA First Draw Form 2483-C (Paycheck Protection Program Application Form) (3/3/2021)
- SBA Form 2484 (Paycheck Protection Program Lender’s Application for 7(a) Loan Guaranty) (Rev. 3/3/2021)
- SBA Form 3506 (Lender Agreement for Federally-insured Credit Unions) (Updated January, 2021)
- SBA Procedural Notice – PPP Lender Processing Fee Payment and Reporting
- SBA Procedural Notice – Second Updated PPP Lender Processing Fee Payment and Reporting (2/9/2021)
- SBA Procedural Notice Paycheck Protection Program Loans and Changes of Ownership (Updated 10/5/2020)
- SBA Procedural Notice - Revised SBA Paycheck Protection Platform Procedures for Addressing Hold Codes on First Draw PPP Loans and Compliance Check Error Messages on First Draw PPP Loans and Second Draw PPP Loans (2/16/2021)
- SBA Procedural Notice – Process for submitting PPP loan forgiveness applications to SBA (Updated 7/29/2020)
- SBA Procedural Notice – Updated First Draw Paycheck Protection Program Loan Increases (Added 4/23/2021)
- Top-line overview
NCUA Resources:
- NCUA Examiner’s Guide – PPP
- NCUA Letter 20-CU-11 – Regulatory Treatment for Paycheck Protection Program Loans
- NCUA Letter – 20-CU-06 – SBA Loan Programs to Help Small Businesses and Members During COVID-19
2021 PPP Resources:
- Exclusive PPP Loan Application Period – Business and Nonprofits with fewer than 20 employees (Available from 2/24/2021 until 3/10/2021)
New PPP Second Draw Loan Information
- SBA Form 2483-SD – Second Draw Borrower Application (Rev. 3/3/2021)
- SBA Form 2483-SD-C – Second Draw Borrower Application (3/3/2021)
- SBA Form 2484-SD – Second Draw Lender Guaranty Application (Rev. 3/3/2021)
New PPP Loan Forgiveness Information
- SBA Form 3508S – PPP Loan Forgiveness Form
- SBA Procedural Notice – PPP Borrower Resubmission of Loan Forgiveness Applications
Guidance and Resources
- Accessing Capital for Minority, Underserved, Veteran and Women-Owned Business Concerns
- Top Line Overview PPP First Draw Loans (1/8/2021)
- Top Line Overview PPP Second Draw Loans (1/8/2021)
- Procedural Notice: Modification to PPP Forms (1/6/2021)
- Procedural Notice: Repeal of EIDL Advance Deduction Requirement (1/8/2021)
Paycheck Protection Program: Model Policies and Procedures
Model Policies
The following policy from CU PolicyPro can be used to help you craft your own policy on this topic:
- Model Policy 7436: CARES Act – Small Business Administration (SBA) Loans - updated 2/26/2021
We recommend reviewing your own policies to see if this policy or similar policies have already been customized and are in use by your credit union. If you're not sure if your credit union subscribes to CU PolicyPro, contact policysupport@cusolutionsgroup.com for assistance.
Sample Procedures